u.s. environmental protection agency announces the record

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U.S. Environmental Protection Agency announces the

Record of Decision Amendment Proposed Plan

Figure 1 – The CERCLA Process

This Record of Decision (ROD) Amendment Proposed Plan, part of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) process (Figure 1), describes the proposed changes to the remedy selected at the Imperial Refining Company (IRC) Superfund Site (Site), Ardmore, Oklahoma, and provides the rationale for these changes. This document is issued by the U.S. Environmental Protection Agency (EPA), the lead agency for Site activities, and the Oklahoma Department of Environmental Quality (ODEQ), the support agency. The final remedy will be selected for the Site after reviewing and considering all information submitted during the 30-day public comment period (see right). EPA, in conjunction with ODEQ, may modify the response action presented in this Proposed Plan based on new information or public comments. Therefore, the public is encouraged to review and comment on this ROD Amendment Proposed Plan.

EPA and ODEQ are issuing this ROD Amendment Proposed Plan as part of their public participation responsibilities under Section 300.430(f)(2) of the National Oil and Hazardous Substances Pollution Contingency Plan and Section 117(a) of the CERCLA Act of 1980.

SITE BACKGROUND The IRC Superfund Site is the location of a petroleum refinery that operated from 1917 to 1934. Numerous tanks and buildings were present on the Site during refinery operations, but

all of the tanks and most of the buildings were dismantled sometime between 1934 and 1948 leaving the property as mixed wooded areas and open fields.

The Site is located in the northeastern portion of Ardmore, Carter County, Oklahoma, and covers approximately 72 acres that is bisected by U.S. Highway (Hwy) 142 and railroad tracks operated

Dates to Remember:

Public Comment Period: November 3, 2008 – December 3, 2008 The EPA and ODEQ will accept written comments on the ROD Amendment Proposed Plan during the public comment period.

Public Meeting: November 18, 2008 The EPA will hold a public meeting to explain the ROD Amendment Proposed Plan. Oral and written comments will also be accepted at the meeting. The meeting will be held at Ardmore Public Library, 320 E Street NW, Ardmore, Oklahoma at 6:00 pm.

The Administrative Record is available for viewing at:

Ardmore Public Library320 E Street NW, Ardmore, Oklahoma 580-223-8290 Hours: 10am to 8:30pm Monday thru Thursday

10am to 4pm Friday thru Saturday 1pm to 5pm Sunday

Oklahoma DEQ707 N. Robinson, 6

th Floor Central Records

Oklahoma City, Oklahoma 405-702-6145 Hours: 8:00am to 4:30pm Monday thru Friday

Superfund Program Record of Decision Amendment Proposed Plan Imperial Refining Company Superfund Site Region 6 Ardmore, Oklahoma

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ROD Amendment Proposed Plan IRC Superfund Site, Ardmore, Oklahoma

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by the BNSF Railway Company. The Site is divided into three parcels: the West (36.5 acres), East (14.5 acres) and East Railroad (21 acres). The primary physical features on the Site include 15 Vertical Tank berms, 18 intermittent drainages, Sand Creek, an underground storage tank, 12 waste piles, 2 ponds, and a central ridge that trends northwest to southeast (Figure 2).

Current and future zoning maps produced by the City of Ardmore depict portions of the Site west of Hwy 142 and east of the railroad tracks as light industrial and portions of the Site east of Hwy 142 and west of the railroad tracks as heavy industrial. The adjacent property to the north is occupied by a facility that manufactures roofing shingles, to the west are waste water processing lagoons operated by Valero Refining, and the rest of the immediately adjacent property is largely undeveloped. Several small businesses, Valero’s active refinery, and a small residential area with about a dozen houses are located within ¼ mile north of the Site. No schools or day care centers have been identified within ¼ mile of the Site.

The ODEQ conducted a Preliminary Assessment at the Site in September 1997 and a Site Inspection during 1998. Based on the results, ODEQ referred the property to the EPA for further action. EPA subsequently conducted Removal Assessments in 1998 and 1999, and a Removal Action to install perimeter fencing in 2004.

The Site was evaluated and proposed to the National Priorities List (NPL) in May 2000 and placed on the NPL in July 2000. The EPA and ODEQ negotiated a Cooperative Agreement under which the ODEQ was the lead agency for the Remedial Investigation/Feasibility Study (RI/FS) with EPA acting as the supporting agency. The EPA settled with the potentially responsible party before the start of the RI/FS.

SITE CHARACTERISTICS From early 2005 through early 2007, contractors for the ODEQ conducted a RI/FS. The RI identified the types, quantities, and locations of contaminants and the FS developed options to address the contamination. Onsite contamination included waste material, soil and sediment containing arsenic and benzo(a)pyrene. The primary sources of contaminants were waste in an underground storage tank and waste piles characterized as dry, asphalt-like material. The waste material was found throughout the Site, and the benzo(a)pyrene concentrations ranged from

2.5 milligrams per kilogram (mg/kg) to 570 mg/kg. In addition to the waste material, surface soil [0-1 foot (ft) below ground surface] and sediment (0-1 ft below ground surface) had elevated concentrations of benzo(a)pyrene and arsenic. The soil concentrations ranged from 1 mg/kg to 90 mg/kg for arsenic and 0.04 mg/kg to 10.2 mg/kg for benzo(a)pyrene. Sediments in onsite intermittent drainages were indistinguishable from Site soils except by their location within drainages; therefore, the drainage sediments were considered soils for the remedial action as these remain dry most of the year.

Throughout the RI/FS process, the community was updated on Site activity through numerous fact sheets, mailings, and open houses. In addition, Site status is updated monthly on the EPA Region 6 website and annually in the ODEQ Land Reports. During the investigation, a website was made available to the public for accessing current Site documents and submitting questions.

RECORD OF DECISION DECEMBER 2007After review and response to comments, the Record of Decision was signed on December 26, 2007. Remedial Action Objectives (RAOs) were developed for Site soil, sediment, and waste material and are listed below. Table 1 present the Site-specific cleanup levels by medium.

Surface Soil• Prevent exposure to current and future human and ecological receptors through ingestion, dermal contact, and inhalation of contaminated soil containing arsenic and benzo(a)pyrene concentrations in excess of 5E-05 and 2.5E-05 excess cancer risk, respectively.

Pond and Creek Sediment• Prevent exposure to current and future human receptors through ingestion, dermal contact, and inhalation of contaminated sediment containing arsenic concentrations in excess of 5E-05 excess cancer risk. • Prevent exposure to current and future ecological receptors through direct contact, foodchain uptake, and incidental ingestion of contaminated sediment containing benzo(a)pyrene concentrations in excess of levels that are protective of ecological receptors.

Waste Material• Prevent exposure to human and ecological receptors through ingestion and dermal contact.

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Table 1: Site-Specific Cleanup Levels by MediumContaminants of Concern

Site-SpecificCleanup Levels

Soil, Residential (mg/kg)

Benzo(a)pyrene 1.55

Arsenic 20

Pond & Creek Sediment, Residential/Ecological (mg/kg)

Benzo(a)pyrene 0.782

Arsenic 20

• Prevent further migration of waste material contamination.

The ROD addressed the Site as one operable unit where the final response action of Excavation and Offsite Disposal would address Site contaminants and waste material through the following:

• 13,083 cubic yards (yd3) of waste material will be

removed and disposed offsite at an appropriately regulated facility based on results from toxicity characteristic leaching procedure (TCLP) analyses. This addresses the principal threat waste at the Site. • 16,438 yd

3 of arsenic and benzo(a)pyrene

contaminated soil will be excavated and disposed offsite at an appropriately regulated facility based on results from TCLP analyses. • 1,633 yd

3 of arsenic and benzo(a)pyrene

contaminated sediment will be excavated and disposed offsite at an appropriately regulated facility based on results from TCLP analyses.

REMEDIAL DESIGN A detailed remedial design was not performed due the simplicity of the Excavation and Offsite Disposal remedy. A value engineering evaluation and the Remedial Design And Remedial Action Work Plan were completed on January 30, 2008. During the work plan development additional field activity was not considered necessary as the extent of waste was presumed to be known.

REMEDIAL CONSTRUCTION ACTIVITIES The EPA began onsite remedial action (RA) construction February 13, 2008. As excavation of the waste material began and continued into the following weeks, it became clear that the vertical and horizontal extents were understated, and the original volume estimate was low. Although, the expectation was to exceed the original volume and cost estimates, attempts were made to meet the residential cleanup levels. As excavation activities

progressed, waste was found to exist in locations where removal would be both impracticable and unsafe. Due to the increase in horizontal and vertical extent, increase in volume, and locations where waste remains in place, aspects of the original remedy were reevaluated. On July 17, 2008, EPA and ODEQ held a public meeting to discuss site progress, activities remaining, and the areas where waste would remain in place.

BASIS FOR THE DOCUMENT The following sub-sections describe, in detail, the Site information and circumstances that prompted and support the fundamental change in the remedy as identified in the 2007 ROD.

1. Cost: The original cost estimate to implement the Excavation and Offsite Disposal remedial action described in the 2007 ROD was $4.4 million (net present worth). Costs were estimated at a discount rate of 7% with no operations and maintenance (O&M) or five-year reviews. Due to the increase in waste volume, a revised cost estimate for the project is projected to be $6,500,000. The difference between the 2007 ROD estimate and the revised cost estimate is due to the increased costs associated with the increased volume of waste material excavated and disposed offsite as well as the inclusion of backfill material necessary for Site restoration and grading. In addition, five-year reviews and O&M will be required and the estimated cost, projected for a timeframe of 30 years is $179,131.47 (Table 2). A complete breakdown of the final costs and details related to O&M activities will be presented in the final RA report and the final O&M plan.

2. Volume (Figure 3): Refinery wastes were encountered at depths up to 10 feet below ground surface and in locations not previously identified during the remedial investigation. Therefore, the discovery and excavation of these new locations increased the volume of waste material disposed. Because these were defined as principal threat wastes, excavation and disposal was necessary to eliminate the wastes as a source of contamination for soil, sediment, surface water, and ground water as well as eliminate the threat to human health and the environment. The estimated volume of material excavated and disposed offsite is 104,493.5 yd

3/105,770.76 tons which represents

an increase of 74,972.5 yd3/55,954.76 tons over

the estimated 29,521 cubic yards/49,816 tons presented in the 2007 ROD. A complete breakdown of the final volume will be presented in the final RA report.

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3. Cleanup Levels: The cleanup scenario presented in the 2007 ROD is based on the child resident. When the industrial and residential soil scenarios were compared, it was noted that cleanup to a residential scenario minimally increased soil volume (690 yd) and cost ($252,068); it would result in unlimited use and unrestricted exposure; and would be protective for all other human and terrestrial ecological receptors. Therefore, in order to be protective for Site reuse under a residential scenario and meet the RAOs, cleanup levels in the 2007 ROD were established for the primary contaminants of concern, arsenic (5E-05 excess lifetime cancer risk) and benzo(a)pyrene (2.5E-05 excess lifetime cancer risk).

The widespread extent, depth, and location of the waste material discovered across the Site during the remedial action have made excavation impracticable and potentially dangerous in some areas. Because of this, waste material remains in place (see sub-section 11. Waste left in place), which makes the residential scenario no longer suitable for this Site. Therefore, current and future landuse information, the final human health risk assessment, and the final ecological risk assessment were reviewed and used to establish a cleanup scenario appropriate for existing Site circumstances.

Current and future zoning maps produced by the City of Ardmore depict portions of the Site west of Hwy 142 and east of the railroad tracks as light industrial and the portion of the Site east of Hwy 142 and west of the railroad tracks as heavy industrial. The human health risk assessment evaluated risk for the industrial worker and shows that the excess lifetime cancer risk for an industrial worker fell within the risk range of 1E-04 to 1E-06 and the non-carcinogenic risk is less than 1. The excess lifetime cancer risk is primarily associated with the ingestion and dermal contact pathways related to arsenic and benzo(a)pyrene in the soil and sediment. Because the exposure pathways and contaminants of concern are the same as those identified for the future child resident, the RAOs presented in the 2007 ROD remain unchanged. Therefore, changing from a residential scenario to an industrial scenario is protective, and in order to meet the RAOs under an industrial scenario, revised cleanup levels are established.

In the absence of federal or state cleanup standards for soil contamination, the Site cleanup levels are based on the baseline risk assessment.

The arsenic cleanup level remains set at 20 mg/kg which is within the range for Oklahoma background soils, represents an excess upper bound lifetime cancer risk to an individual of 5E-05 which is within EPA’s cancer risk range of 1E-06 to 1E-04, is below the non-cancer benchmark of 1, and is considered protective of human health and the environment. Using all assumptions and calculations presented in the human health risk assessment, the cleanup level for benzo(a)pyrene (2.5E-05 excess lifetime cancer risk) under an industrial reuse scenario is 5.27 mg/kg, which is within EPA’s cancer risk range of 1E-06 to 1E-04 and is considered protective of human health and the environment. Despite the change in the cleanup level, these risk drivers remain co-located with other metals and organics as well as areas of ecological risk associated with the upland habitat (soil) and wet areas (sediment not in the ponds or creek); therefore, revision of the ecological cleanup levels is not necessary.

Because the Site will be restricted to industrial use and is not available for unlimited use and unrestricted exposure, institutional controls, O&M, and five-year reviews will be required. These activities are applicable to the entire Site.

4. Waste left in place (Figure 4): The widespread extent, depth, and location of the waste material discovered across the Site during the remedial action have made excavation impracticable and potentially dangerous in some areas. Excavation and removal activities have progressed to the extent practicable; however, there will be areas where waste remains. This waste material has been identified as a non-hazardous waste. Site TCLP data indicate that the leaching potential of this material is low as all results have been below regulatory limits for characteristic hazardous waste categories and land disposal restrictions. As such, backfill of the excavated areas and areas above the waste material with clay provides for slope control, drainage control, and the establishment of vegetation. In addition, clay backfill will mitigate the potential for direct exposure and migration.

a. Ponds: All surface sediments that exceeded the ecological cleanup level have been excavated and confirmation samples have been collected. The confirmation sample results are below the ecological cleanup level of 0.782 mg/kg. Based on excavation activities along the drainages and shore lines, waste was documented at depths greater than 18 inches and extending

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out into the ponds. Additional delineation pits were excavated within the east and west ponds to identify the extent of the waste layer. The delineation pits indicated that the waste is widespread and continued to be present under at least 18 inches of uncontaminated overburden. The presence of the overburden and its thickness is expected to act as a barrier between the waste and the surface sediments as well as provide ample non-contaminated burrowing material above the waste for benthic invertebrates. This is supported by the surface sediment results from the remedial investigation and those confirmation samples collected during the remedial action. In addition, erosion and scouring of the overburden is not expected as these ponds are stagnant for most of the year and high flow velocity currents are rare.

b. Northern boundary with Atlas Roofing, Inc.: The northern boundary of the eastern parcel is a slope approximately 10 to 15 feet in height. Atlas Roofing, Inc. is built on the land at the top of this slope. Excavation activities along this border indicate that waste materials extend into this slope; the exact extent is unknown. Excavation and removal of waste along this border is not feasible or practical as this may alter the stability and integrity of the slope as well as the foundation on which Atlas Roofing, Inc. is built.

c. Site boundaries with Hwy 142: The situation is similar to the northern border with Atlas Roofing, Inc. The highway sits atop a slope approximately 10 to 15 feet in height. Excavation activities along the eastern and western borders of Hwy 142 indicate that waste materials extend into the slope and under the highway exposing itself on the opposite side. Excavation and removal of waste along these borders and under the highway is not feasible or practical as this may alter the stability and integrity of the slope and the highway.

d. Northern and western boundaries with Valero Refinery Property: During excavation activities, it was determined that waste extends across the shared western and northern property boundaries with Valero Refinery. ODEQ’s Resource Conservation and Recovery Act section will be working with Valero Refinery to address the waste along these borders.

e. Oneok gas pipeline: Excavation in close proximity to the high pressure gas line was not recommended or considered safe; therefore,

waste remains around the gas line and within the easement boundaries of the pipeline.

f. Site boundary with BNSF railway:During excavation activities, it was determined that waste extends across the shared property boundary with BNSF railway; the exact extent is unknown. Excavation in close proximity to the rail line is not recommended as this may alter the stability and integrity of the slope and rail line construction; therefore, waste remains on the BNSF property.

DESCRIPTION OF NEW ALTERNATIVE The 2007 ROD identified Excavation and Offsite Disposal as the remedy for soil, sediment and waste. This component remains unchanged and was implemented to the extent practicable. In total, approximately 104,493.5 yd

3 of waste/soil

and approximately 1699.5 yd3 of sediment were

removed from the Site and shipped to an offsite landfill. The following component is included to address those areas where waste remains. Table 3 outlines the differences between the original 2007 ROD and this ROD Amendment Proposed Plan.

Containment: This alternative includes the placement of a clay barrier over waste material that remains in place. This alternative will achieve all RAOs by mitigating exposure and migration through engineering controls, institutional controls, and monitoring during O&M and five-year reviews. The waste materials remaining are identified as non-hazardous waste and all TCLP data indicate that the leaching potential of this material is low as all results have been below regulatory limits for characteristic hazardous waste categories and land disposal restrictions. The backfill material is identified as a clayey sand and is expected to have a low hydraulic conductivity (within the range of 10-3 centimeters per second to 10-5 centimeters per second) which limits water infiltration and further reduces the potential for leaching. As such, backfill of the excavated areas and areas above the waste material with the clayey sand reduces the potential for direct contact, ingestion, and migration as well as provides for slope control, drainage control, and the establishment of vegetation.

Because the contaminants will be left in place, this remedy will be compliant with the Oklahoma Solid Waste Management Act. The Site will be restricted to industrial use, available for limited

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reuse in areas where the waste remains in place, require O&M, and require five-year reviews.

a. Clay Barrier: i. Ponds: Due to the presence of

uncontaminated overburden, the complete removal of surface sediment exceeding the ecological cleanup numbers, and the unknown locations of waste at depth throughout the remaining areas of the ponds, no further excavation will occur. Excavated areas will be backfilled with clean material and an institutional control (IC) will be placed on the ponds. O&M activities will be conducted by ODEQ and five-year reviews will be conducted by EPA to ensure protectiveness.

ii. Northern boundary with Atlas Roofing, Inc.: An engineering evaluation identified suitable slope stabilization and construction activities and backfill material for placement on the waste. As backfill material is imported, a slope of no greater than 3 feet vertical to 1 foot horizontal will be maintained along this border to minimize erosion and facilitate slope support, drainage control, and re-vegetation. Atlas Roofing, Inc. will place an institutional control on the Atlas Roofing, Inc. property. O&M activities will be conducted by ODEQ in coordination with Atlas Roofing, Inc., and five-year reviews will be conducted by EPA.

iii. Site Boundaries with Hwy 142: An engineering evaluation identified suitable slope stabilization and construction activities and backfill material for placement on the waste. As backfill material is imported, a slope of no greater than 3 feet vertical to 1 foot horizontal will be maintained along this border to minimize erosion and facilitate slope support, drainage control, and re-vegetation. The Oklahoma Department of Transportation (ODOT) will place an institutional control on Hwy 142 and its associated utility easements. O&M activities will be conducted by ODEQ in coordination with the Oklahoma Department of Transportation, and five-year reviews will be conducted by EPA.

iv. Northern and Western Boundaries with Valero Refinery property: Backfill of the

excavated areas and areas above the waste material provides for slope control, drainage control, and establishment of vegetation. As backfill is placed, the drainage along this boundary will be re-directed away from these waste areas in an effort to mitigate erosion, ensure drainage control, and facilitate re-vegetation. O&M activities will be conducted by ODEQ, and five-year reviews will be conducted by EPA.

v. Oneok Gas Pipeline: As backfill material is imported, a gentle slope will be maintained along this border to minimize erosion and facilitate slope support, drainage control, and re-vegetation. The clay backfill will be placed on either side of the pipeline and clay overburden, at a depth of approximately two feet, will be placed along the top of the gas line to provide a barrier for the pipeline and promote surface water runoff. ODEQ will place an IC on the easement and conduct O&M activities in coordination with Oneok. Five-year reviews will be conducted by EPA.

vi. Site Boundary with BNSF Railway: As backfill material is imported, a gentle slope will be maintained along this border to minimize erosion and facilitate slope support, drainage control, and re-vegetation. O&M activities will be conducted by ODEQ in coordination with BNSF, and five-year reviews will be conducted by EPA to ensure protectiveness.

b. Operations and Maintenance: Because waste remains in place and the Site will be restricted to industrial use, O&M activities will be conducted by ODEQ no less often than once per year and will be required to ensure remedy protectiveness. O&M activities will include Site inspections for erosion, property uses, and enforcement of the ICs. This activity may also include maintenance of the slopes through grading, seeding, or importing of backfill that may be needed. Maintenance of these slopes will provide continued slope support, continued drainage control, continued vegetation growth, and ensure that exposure and migration is not occurring. Areas of primary interest will include the slopes along Hwy 142, Atlas Roofing Inc.,

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Table 3: Comparisons of the Differences between the 2007 ROD and ROD Amendment Proposed Plan

Component 2007 ROD ROD Amendment Proposed Plan

Difference

Soil Cleanup Levels Residential: 20 mg/kg arsenic 1.55 mg/kg benzo(a)pyrene

Industrial:20 mg/kg arsenic 5.27 mg/kg benzo(a)pyrene

Residential Scenario versesIndustrial Scenario

Soil and Waste Volume 29,521 yd3 104,493.5 yd

3 74,972.5 yd

3 increase

Waste Remaining in Place All waste removed Waste Remaining in Place Waste Remaining in Place

Institutional Controls No ICs ICs included No cost Difference

O&M (present value cost estimated for 30 year time period)

No Cost $119,532.57 $119,532.57 increase

Five-year Reviews (present value cost estimated for 30 year time period)

No Cost $59,598.90 $59,598.90 increase

Remedial Cost $4,390,141 $6,500,000 $2,109,859 increase

Oneok Gas Pipeline, BNSF Railway, and Valero Refining.

c. Institutional Controls: Because waste remains in place and the Site will be restricted to industrial use, institutional controls will be required. The purpose of this IC is to inform the general public of the restrictions and circumstances of the Site so that the risk of exposure is minimized. In accordance with Oklahoma Statutes, 27A § 2-7-123 (B), the ODEQ has the authority to file a Notice of Remediation or Related Action Taken Pursuant to the Federal Comprehensive Environmental Response, Compensation and Liability Act (Attachment 1, template example). This notice will identify the reason for notice, the affected property, the remedy activities conducted on the Site, the engineering controls used on the Site, continuing operation, maintenance and monitoring activities that will be conducted, and the land use restrictions. This notice will also describe the proper management and disposal of the material should construction activity within these areas be required. This notice will run with the land and no change of ownership will change the land use restrictions. Any changes to these restrictions will be proposed to ODEQ for review and if approved, ODEQ may remove or alter the notice and land use restrictions. During O&M activities, these ICs will be reviewed to ensure that the restrictions remain in place and that any Site activities adhere to these restrictions. The expected timeframe for filing the ICs is approximately 3 months.

d. Five-year Reviews: Because this remedy will result in hazardous substances, pollutants, or contaminants remaining onsite above levels that allow for unlimited use and unrestricted exposure, a five-year review will be required for this remedial action no less than every five years and will be conducted by EPA in coordination with ODEQ. The purpose of the five-year review is to evaluate the Site remedy for continued protectiveness. A Site inspection will be conducted to provide information about Site status and to visually confirm and document the conditions of the remedy, the Site, and the surrounding area. Observations will be made for any evidence of erosion and potential contaminant migration, property uses, trespass and vandalism and any corrective measures that were taken during operation and maintenance. As Site condition and data warrant, sediment sampling may be conducted once every five-years in order to evaluate the continued protectiveness of the sediment overburden in the ponds. Data and other pertinent Site-specific information will be reviewed to determine whether maintenance procedures, as implemented, will maintain the effectiveness of response actions. This will include review of sampling and monitoring plans, results from monitoring activities, O&M reports, and previous five-year reviews.

In addition to Site-specific information, the original assumptions regarding current and future land/groundwater uses and contaminants of concern will be reviewed to make sure that these are still valid. Along with this, physical features

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Evaluation Criteria for CERCLA Remedial Alternatives

Overall Protection of Human Health and the Environmentdetermines whether an alternative eliminates, reduces, or controls threats to public health and the environment through institutional controls, engineering controls, or treatment.

Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) evaluates whether the alternative meets Federal and State environmental statutes, regulations, and other requirements that pertain to the site, or whether a waiver is justified.

Long-term Effectiveness and Permanence considers the ability of an alternative to maintain protection of human health and the environment over time.

Reduction of Toxicity, Mobility, or Volume of Contaminants through Treatment evaluates an alternative's use of treatment to reduce the harmful effects of principal contaminants, their ability to move in the environment, and the amount of contamination present.

Short-term Effectiveness considers the length of time needed to implement an alternative and the risks the alternative poses to workers, residents, and the environment during implementation.

Implementability considers the technical and administrative feasibility of implementing the alternative, including factors such as the relative availability of goods and services.

Cost includes estimated capital, periodic, and annual operations and maintenance (O&M) costs, as well as present worth cost. Present worth cost is the total cost of an alternative over time in terms of today's dollar value. Cost estimates are expected to be accurate within a range of +50 to -30 percent.

State/Support Agency Acceptance considers whether the DEQ and USEPA agree with the analyses and recommendations, as described in the RI/FS and Proposed Plan.

Community Acceptance considers whether the local community agrees with ODEQ's analyses and preferred alternative. Comments received on the Proposed Plan are an important indicator of community acceptance.

and the understanding of physical site conditions will be reviewed for any changes that may effect changes in standards and assumptions that were used at the time of remedy selection. The five-year review will also evaluate any changes in the promulgated standards or “to be considered” standards as well as risk parameters that may impact the protectiveness of the remedy.

EVALUATION OF ALTERNATIVES Nine criteria are used to evaluate the different remediation alternatives individually and against each other in order to select a remedy. In the following analysis, the original Excavation and Offsite Disposal remedy is compared with the Excavation and Offsite Disposal plus Containment alternative in relation to each of the nine criteria.

1. Overall Protection of Human Health and the EnvironmentBoth alternatives will provide adequate protection of human health and the environment by eliminating, reducing, and/or controlling risk through excavation and offsite disposal, containment, engineering controls, institutional controls, and Site monitoring through O&M and five-year reviews.

2. Compliance with applicable or relevant and appropriate requirements (ARARs)These alternatives will comply with the Endangered Species Act, 16 U.S.C. §§ 1531 et seq. and the Executive Order on Floodplain Management, and will meet substantive requirements of the National Emission Standards for Hazardous Air Pollutants, 40 CFR Part 61; the Oklahoma Clean Air Act, 27A O.S. § 2-6-101 et seq.; and ODEQ’s Air Pollution Control rules OAC 252:100 relevant to particulate matter and air pollutants. Based on TCLP results, the material will be disposed offsite in an appropriate permitted and regulated landfill. Land disposal restrictions (LDRs) will not apply to offsite disposal alternatives if the contaminants in soils, sediments, and waste material are non-hazardous. The alternative that includes onsite containment is not required to meet LDR standards or minimum technology requirements if contamination is non-hazardous. Because the contaminants will be left in place, these alternatives will be compliant with the Oklahoma Solid Waste Management Act, 27A O.S. § 2-10-101 et seq. and ODEQ’s Solid Waste Management rules, OAC 252:515.

3. Long-term Effectiveness and PermanenceExcavation and Offsite Disposal will be the most effective and permanent in the long-term as the potential for exposure or offsite migration is completely eliminated through removal of contamination from the Site. This alternative will not require O&M or institutional and engineering controls. Excavation and Offsite Disposal plus Containment will provide the same level of long-term protectiveness in areas where contamination is removed; however, for areas where contamination remains, construction of a clay barrier will be necessary to mitigate the potential for exposure and contaminant migration. This alternative will be effective and permanent in the long-term as long as O&M is performed, Five-Year

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Reviews are conducted and institutional controls are enforced.

4. Reduction of Toxicity, Mobility, or Volume of Contaminants through TreatmentNeither alternative will reduce toxicity, mobility, and volume through treatment. Excavation and Offsite Disposal removes contamination from the Site; therefore, only mobility is reduced although not through treatment. Excavation and Offsite Disposal plus Containment will be least effective at reducing toxicity, mobility, and volume through treatment because contamination will be left onsite and neither toxicity or volume of material will be addressed. This alternative only reduces mobility although not through treatment.

5. Short-term EffectivenessEach alternative is effective in the short-term and will attain RAOs in 3 to 6 months. Each alternative may present potential risks to the onsite workers and the community through potential dust emissions during excavation and offsite disposal as well as during placement of the clay barrier. Field dust suppression activities will be conducted to reduce dust emissions. There is additional potential risk for both the onsite worker and the community during offsite trucking for disposal and backfilling. All activity will be in compliance with Occupational Safety and Health Administration requirements 29 CFR 1910 and 1926 for worker safety.

6. ImplementabilityEach alternative is a common, easily implemented practice, and equipment and services are readily available. Although easily implemented, containment requires long-term O&M, five-year reviews, and enforcement of institutional controls.

7. CostThe addition of containment has increased costs related to O&M and Five-year reviews. For comparison and reporting purposes, costs for these activities were evaluated over a 30-year period discounted at a rate of 7 %; however, these activities will be required as long as the property remains restricted and waste remains in place. The estimated cost for the addition of O&M is approximately $179,131.47 (Tables 2 and 3).

8. State/Support Agency AcceptanceThe State of Oklahoma supports this alternative.

9. Community AcceptanceCommunity acceptance of the alternative will be evaluated after the public comment period ends and will be described in the responsiveness summary of the ROD Amendment.

SUMMARY OF THE ROD AMENDMENT REMEDIAL ALTERNATIVE In addition to Excavation and Offsite Disposal, containment will be added to address those areas where waste remains. ICs will be placed on the property to restrict use and Site maintenance through O&M and five-year reviews will be conducted.

The Containment component, along with the Excavation and Offsite Disposal, will meet RAOs and cleanup levels as well as provide adequate protection of human health and the environment by eliminating, reducing, and controlling risk and potential migration through construction of a clay barrier, the use of engineering controls, and the implementation of ICs, O&M activities, and Five-Year reviews. Attainment of the cleanup levels reduces potential human health risk levels such that exposure to soil and sediment through ingestion and dermal contact does not exceed a non-carcinogenic hazard index of 1, an excess cancer risk of 5E-05 arsenic (20 mg/kg), and an excess cancer risk of 2.5E-05 benzo(a)pyrene (5.27 mg/kg) under an industrial scenario. In addition, attainment of cleanup levels reduces potential ecological risk levels for terrestrial receptors such that exposure to soil through ingestion and dermal contact will be acceptable.

All human and ecological risks related to waste material will be mitigated by the placement of the clay barrier and its continued maintenance during O&M. These alternatives are anticipated not to pose any unacceptable short-term risks to either onsite workers or the community. No cross-media impacts are expected.

These remedial actions will be effective and permanent in the long-term provided long-term monitoring, O&M, five-year reviews, and enforcement of institutional controls are performed. The Site will be available for industrial use which is compatible and consistent with future land zoning maps.

Based on the information currently available, the State of Oklahoma and EPA believe the Containment component would meet the threshold

003626


10

criteria and provide the best balance of tradeoffs among other alternatives with respect to the balancing and modifying criteria. The Agencies expect the alternative to satisfy the following statutory requirements of CERCLA Section 121(b): be protective of human health and the environment, comply with ARARs, be cost-effective, and utilize permanent solutions and alternative treatment technologies to the maximum extent practicable. The remedy will not meet the statutory preference for the selection of a remedy that involves treatment as a principal element. Treatment of the contaminated soil, sediment, and waste would not be cost effective since they are not identified as hazardous wastes and can be disposed of in a permitted non-hazardous waste landfill. The ROD Amendment alternative can change in response to public comment or new information.

COMMUNITY PARTICIPATION The EPA and ODEQ provide information regarding the cleanup of the IRC Site to the public through public meetings, the Administrative Record file for the Site, and announcements published in the local newspaper. The EPA and ODEQ encourage the public to gain a more comprehensive understanding of the Site and the Superfund activities that have been conducted at the Site.

The date, location, and time of the public meeting, dates for the public comment period, and the locations of the Administrative Record files are provided on the front page of this ROD Amendment Proposed Plan.

For further information on the Imperial Refining Company Superfund Site, please visit the locations identified on Page 1 to view various site documentation or contact:

Mr. Dennis Datin, Project Manager Oklahoma DEQ

707 N. Robinson, PO Box 1677 Oklahoma City, OK 73101

(405) 702-5125 or [email protected]

Ms. Katrina Higgins-Coltrain, Remedial Project Manager EPA Region 6

1445 Ross Avenue Dallas Texas, 75202

(214) 665-8143 or [email protected]

003627


11

ACRONYMS

ARARs Applicable or Relevant and Appropriate Requirements

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

EPA U.S. Environmental Protection Agency

FS Feasibility Study

Hwy Highway

ICs Institutional Controls

IRC Imperial Refining Company

mg/kg Milligrams per Kilogram

NPL National Priorities List

ODEQ Oklahoma Department of Environmental Quality

O&M Operations and Maintenance

RAOs Remedial Action Objectives

RI/FS Remedial Investigation and Feasibility Study

ROD Record of Decision

TCLP Toxicity Characteristic Leaching Procedure

yd3cubic yards

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12

GLOSSARY OF TERMS

Administrative Record – The body of documents available to the public associated with characterization and remedy selection at a Site.

Applicable or relevant and appropriate requirements (ARARs) – ARARs are the Federal and State environmental laws that a selected remedy will meet. These requirements may vary among Sites and alternatives.

Baseline Risk Assessment – An evaluation of the potential threat to human health and the environment in the absence of any remedial action.

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) - Was enacted by Congress on December 11, 1980. This law created a tax on the chemical and petroleum industries and provided broad Federal authority to respond directly to releases or threatened releases of hazardous substances that may endanger public health or the environment.

Contaminants of Concern – Those chemicals associate with the Site or Site activities that may represent a risk to human health or the environment.

Ecological Risk Assessment – Study that assesses risks to aquatic and terrestrial receptors posed by contaminant releases from a Site.

Engineering Controls – Controls that are engineered to manage environmental or human health risk by limiting access and/or preventing exposure to constituents of concern on the property. These may include such things as fences, signs, or soil covers over contaminated materials.

Excess Lifetime Cancer Risk – Cancer posed by a contaminated Site in excess of the lifetime probability of developing cancer from other causes.

Feasibility Study (FS) – Identifies and evaluates the appropriate technical approaches and treatment technologies to address contamination at a Site.

Human Health Risk Assessment – A study that determines and evaluates risk that Site contamination poses to human health.

Institutional Controls (ICs) – Institutional controls are actions, such as legal controls, that help minimize the potential for human exposure to contamination by ensuring appropriate land or resource use.

Milligrams per Kilogram (mg/kg) - A unit of measurement equivalent to one milligram of contaminant per kilogram of solid (typically soil).

Monitoring – Ongoing collection of information about the environment that helps gauge the effectiveness of a cleanup action. For some of the alternatives, monitoring wells would be drilled at the IRC Site to detect any leaks from the containment structures.

National Oil and Hazardous Substance Pollution Contingency Plan – Regulations governing cleanups under EPA’s Superfund program.

National Priorities List (NPL) – The NPL is the list of national priorities among the known releases or threatened releases of hazardous substances, pollutants, or contaminants throughout the United States and its territories. The NPL is intended primarily to guide the EPA in determining which Sites warrant further investigation.

Present Worth Cost – A method of evaluation of expenditures that occur over different time periods. By discounting all costs to a common base year, the costs for different remedial action alternatives can be compared on the basis of a single figure for each alternative. When calculating present worth cost for Superfund sites, total operations & maintenance costs are to be included.

Remedial Action – Action(s) taken to correct or remediate contamination.

Remedial Action Objectives (RAOs) – Specific goals for protecting human health and the environment. RAOs are developed by evaluating ARARs that are protective of human health and the environment and the results of the remedial investigations, including the human and ecological risk assessments.

Record of Decision (ROD) – A formal document that is a consolidated source of information about a Superfund Site, the remedy selection process, and the selected remedy.

003629


13

Remedial Investigation (RI) – A study conducted to identify the types, amounts, and locations of contamination at a Site.

Resource Conservation and Recovery Act – The Federal act that established a regulatory system to track hazardous wastes from the time they are generated to their final disposal. RCRA also provides for safe hazardous waste management practices and imposes standards for transporting, treating, storing, and disposing of hazardous wastes.

Toxicity Characteristic Leaching Procedure (TCLP) – A standardized testing procedure used to determine whether materials are hazardous under the definition of the Resource Conservation and Recovery Act (RCRA).

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14

USE THIS SPACE TO WRITE YOUR COMMENTS

Your input on the ROD Amendment Proposed Plan for the IRC Site is important to the ODEQ and EPA. Comments provided by the public are valuable in helping the ODEQ and EPA select a final cleanup remedy for the Site.

You may use the space below to write your comments, then fold and mail. Comments must be postmarked by December 3, 2008. If you have any questions about the comment period, please contact Dennis Datin at (405) 702-5125, Katrina Higgins-Coltrain at (214) 665-8143, or through EPA’s toll-free number at 1-800-533-3508. Those with electronic communications capabilities may submit their comments to the ODEQ or EPA via Internet at the following e-mail addresses: [email protected] or [email protected].

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Name _______________________________________________

Address _____________________________________________

City ________________________________________________

State____________________ Zip _______________________

003631

f

W E

N

ROD Amendment Proposed PlanIRe Superfund Site, Ardmore, Oklahoma

S310:: '''===.'__ 310"".

15

Figure 2 - Site FeaturesImperial Refining ~ompany,

Legend~ Tar-mat Waste Area ryvA-A)

Site Boundary 0 Vertical Tank Remenant (VTR1)

D · Drainage Flow DirectionProcess Area Railroad

-- Historical Road Drainage (DR1)

003632

ROD Amendment Proposed PlanIRe Superfund Site, Ardmore, Oklahoma

16

Legend

EXCAVATED AREAS

o SITE BOUNDARY

o 155 310 620"..ii:= ilFeet

1 inch = 375 feet

~ .....t/" 'J USEPA REGION 6~~ START-3

Figure 3Excavated Areas Map

ArdmoreCarter County, Oklahoma

ATE F'ROJEcr ~o so.o.LEOCT200! 2O..:Je.o12,00lI.02~3.01 MSHOWN

003633

ON

EO

K

Figure 4: Waste remaining in place.

Legend: Blue Lines represent the Site Boundaries.

Red dotted lines represent the estimated boundaries of the waste remaining in place.

Green line represents the location of the Oneok high-pressure gas line.

ROD Amendment Proposed PlanIRC Superfund Site, Ardmore, Oklahoma

17

003634

Table 2: Operations and Maintenance Costs

O&M Costs

Quantity Units

Cost Per

Unit

Total Estimated

Cost NotesO&M Cost Yr 1-30

75 CY $23.00 $1,725.00

2 acre $10.00 $20.00

1 week $2,500.00 $2,500.00 rental fee for dozer

Backfill Equipment Operator 10 HR $60.00 $600.00

Field Staff for seeding and backfill 20 HR $100.00 $2,000.00Assume oversight for seeding and backfilling. Each event estimated to take 10hrs.

Site Inspections 8 HR $100.00 $800.00 1 person hourly rate + travel + other external cost

Subtotal $7,645.00

Contingency 20% $1,529.00Subtotal $9,174.00

5% $458.70$9,632.70

Year Quantity Units Unit Cost Notes5 1 LS $20,000.00 $20,000.005 1 LS $1,000.00 $1,000.00

Pond Sediment sampling 1 LS $2,000.00 $2,000.00 Two persons for two days: 10 hours per day

Laboratory Chemical Analysis 6 EA $220.00 $1,320.00Estimated $20/sample for arsenic analysis and $200/sample for Benzo(a)pyrene. 3 samples for each pond.

Chemical Data Management 6 EA $50.00 $300.00 1 for each event (1 hr per sample per analyte * $50/hr)1 LS $2,000.00 $2,000.00 includes lodging/per diem/rental car/gas1 LS $1,000.00 $1,000.00 includes sample supplies/boat/sediment sample equipment

Subtotal $27,620.00

10 1 LS $20,000.00 $20,000.0010 1 LS $1,000.00 $1,000.00




Subtotal $27,620.00

15 1 LS $20,000.00 $20,000.0015 1 LS $1,000.00 $1,000.00




Subtotal $27,620.00

20 1 LS $20,000.00 $20,000.0020 1 LS $1,000.00 $1,000.00




Subtotal $27,620.00

25 1 LS $20,000.00 $20,000.0025 1 LS $1,000.00 $1,000.00

Pond Sediment sampling 1 LS $2,000.00 $2,000.00



Subtotal $27,620.00

30 1 LS $20,000.00 $20,000.0030 1 LS $1,000.00 $1,000.00

Pond Sediment sampling 1 LS $2,000.00 $2,000.00



Subtotal $27,620.00

Cost Type Year

Discount

Factor (7%) Present Value Notes

Annual O&M Cost 1-30 12.41 $119,532.57

Periodic Cost 5 0.71 $19,692.68

Periodic Cost 10 0.51 $14,040.61

Periodic Cost 15 0.36 $10,010.76

Periodic Cost 20 0.26 $7,137.53

Periodic Cost 25 0.18 $5,088.96

Periodic Cost 30 0.13 $3,628.36$179,131.47

Description

Site Maintenance

Soil for Erosion

Update Institutional Controls Plan

Project ManagementTOTAL ANNUAL O&M COST (1-30)

PERIODIC COSTS

Field Staff Travel

Sample equipment and supplies

Five Year Review Report




Field Staff Travel




Monitoring/Sampling

PRESENT VALUE ANALYSIS

Total Cost Total Cost Per Year


Monitoring/Sampling

Field Staff Travel


$288,981.00 $9,632.70$27,620.00 $27,620.00$27,620.00 $27,620.00$27,620.00 $27,620.00

$27,620.00 $27,620.00

Monitoring/Sampling

Monitoring/Sampling

Monitoring/Sampling

$27,620.00 $27,620.00$27,620.00 $27,620.00

Seeding

Backfill Equipment

Field Staff Travel


Field Staff Travel


DescriptionFive Year Review Report



Monitoring/Sampling

Field Staff Travel



ROD Amendment Proposed PlanIRC Superfund Site, Ardmore, Oklahoma

18003635

ROD Amendment Proposed Plan

IRC Superfund Site, Ardmore, Oklahoma

19

Attachment 1: Institutional Control Template Example

NOTICE OF REMEDIATION OR RELATED ACTION TAKEN PURSUANT TO THE

FEDERAL COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION

AND LIABILITY ACT and CREATION OF EASEMENT

IMPERIAL REFINING SUPERFUND SITE

LEGAL BASIS FOR NOTICE: The Oklahoma Department of Environmental Quality

(“DEQ”) hereby files this NOTICE OF REMEDIATION OR RELATED ACTION TAKEN

PURSUANT TO THE FEDERAL COMPREHENSIVE ENVIRONMENTAL RESPONSE,

COMPENSATION AND LIABILITY ACT AND CREATION OF EASEMENT (hereinafter

“Notice”) pursuant to Oklahoma Statutes, 27A § 2-7-123 (B). This Notice does not grant any

right to any person not already allowed by law. This Notice shall not be construed to authorize

or encourage any person or other legal entity to cause or increase pollution, to avoid compliance

with State or Federal laws and regulations regarding pollution or to in any manner escape

responsibility for maintaining environmentally sound operations.

The DEQ may take administrative or civil action to recover costs or to compel compliance with

the below described “Land Use Restrictions” and to prevent damage to, or interference with the

below described “Engineering Controls” and “Continuing Operation, Maintenance and

Monitoring.” The Land Use Restrictions, Engineering Controls and Continuing Operation,

Maintenance and Monitoring will apply to the Affected Property and to persons who own and/or

use the Affected Property until such time as the DEQ files a subsequent Notice that changes or

removes the Land Use Restrictions, Engineering Controls and Continuing Operation,

Maintenance and Monitoring set forth below. Activities that cause or could cause damage to the

Remedy or the Engineering Controls described herein below, or recontamination of soil or

groundwater are prohibited.

The owner of the below described Affected Property has the legal authority to create, and does

hereby voluntarily create, an easement granted to the DEQ and its employees and agents, for

ingress and egress through, across and onto the Affected Property to assure the ongoing

protection of the remedy, engineering controls and land use restrictions described herein below.

This easement touches and concerns the land; runs with the land; is legally binding on all future

owners of the Affected Property and will only be removed or modified if and when the DEQ

modifies or removes its land use restrictions or engineering controls in the manner described

herein below.

REASON FOR NOTICE: The below described Affected Property was contaminated with

materials that required remediation pursuant to State and Federal environmental laws and

regulations. The Affected Property was remediated to a risk-based standard.

AFFECTED PROPERTY: The Imperial Refining Company (IRC) Superfund Site is the

location of a former petroleum refinery that operated from 1917 to 1934. IRC remained active

for 17 years until it went bankrupt in 1934. The primary sources of contaminants are vertical

tank remnants, waste in a UST, and waste piles characterized as dry, asphalt-like material.

003636



20

Chemical constituents associated with the waste material have affected soil and sediment. The

Site was addressed as one operable unit where the final response action addressed Site

contaminants and waste material that pose a current or future health risk.

[Insert description of property affected by this IC.]

REMEDY:

Remediation activities (“Remedy”) at the Affected Property included:

a. Excavation and removal of 105,993 cubic yards of waste and contaminated soil

and sediment;

b. Offsite disposal of 107,299.88.35 tons of waste and contaminated soil and

sediment.

c. Surface Water discharge and sampling.

d. Confirmation soil and sediment sampling.

e. Import of approximately 64,366.5 cubic yards of backfill.

f. Site grading for drainage followed by seeding.

Remedial construction completion was accomplished on September 18, 2008, with the signing of

the Preliminary Close Out Report.

ENGINEERING CONTROLS: The engineering controls at this site include clay barriers

located throughout the Site. The clay barriers and the underlying waste that was left in place are

the subject of this notice along with the restricted Site use of industrial.

CONTINUING OPERATION, MAINTENANCE AND MONITORING:

LAND USE RESTRICTIONS: The land use restrictions for the above-described Affected

Property are listed below and apply to the entirety of the Affected Property described herein

above.

a. No digging at or below five (5) feet from the surface in areas where waste

remains in place.

b. No activities that will cause erosion of the soil at or near locations where waste

remains in place.

c. No residential use.

d. Maintenance activities required within the areas where waste remains in place

require ODEQ notification prior to commencement. Any activity within these

areas requires the establishment of health and safety protocols to ensure worker

safety and require that the waste materials encountered are managed properly

while onsite and then disposed offsite in an appropriately permitted and regulated

landfill.

e. No activities that will disturb or cause erosion of the sediments within the ponds

located on the Site.

Changes to the Land Use Restrictions Changes to land use restrictions must be approved by

the Department of Environmental Quality or its successor agency. The person requesting the

change in land use must demonstrate to the DEQ’s satisfaction that contamination at the site has

003637



21

reached levels appropriate for the proposed new land uses and that further remediation is not

necessary or that additional institutional or engineering controls are adequate to achieve levels

protective of human health and the environment for the proposed uses.

The DEQ may require oversight costs, work plans, sampling, reports, and public participation as

part of its review of the new information to support the requested change in land use restrictions.

The person requesting the change will be required to follow agency procedures effective at the

time of the request.

The DEQ at its discretion may determine, based on the new information submitted, that

contaminants are present at the Site at levels that will not pose a risk to human health or the

environment if the new land use restrictions being requested are allowed. Upon making this

determination, the DEQ will file a recordable notice of remediation pursuant to state law in the

land records in the in the office of the county clerk where the Site is located designating the new

land use restrictions.

This Notice and the Land Use Restrictions contained herein run with the land and no change of

ownership of the Affected Property will change the Land Use Restrictions described herein

above. This Notice and the Land Use Restrictions contained herein are effective upon the date of

signature by the Executive Director of the DEQ.

________________________________________ ________________________

Steven A. Thompson, Executive Director Date

Oklahoma Department of Environmental Quality

Subscribed and sworn to before me this _______ day of _______________, 20____.

__________________________________

Notary Public

My Commission expires:

________________, 20___.

003638



22

I hereby certify that I have the legal right to, and do hereby, create an easement and encumber

the real property as described in the foregoing Notice. I hereby voluntarily grant an easement to

the DEQ and its employees and agents, for ingress and egress through, across and onto the

Affected Property to assure the ongoing placement, operation and protection of the remedy,

engineering controls and land use restrictions described herein above.

I have had notice and an opportunity to meet with representatives of the Oklahoma Department

of Environmental Quality to comment on the foregoing Notice and agree herewith. I hereby

agree to the filing of the foregoing Notice and Easement.

________________________________________ ________________________

Owner of the Affected Property Date

_________________________________________ ________________________

(Spouse of, and/or, Owner of the Affected Property) Date

Subscribed and sworn to before me this ____ day of ______________, 20____.

__________________________________

Notary Public

My Commission expires:

________________, 20____.

003639

ConCIIITcncc Page for thc Imperial Relining CompanyRccord of Dccision Amcndmcnt Proposed Plan

~,RdialProject ManagerLNNMJOK -I'cam

Date10-27--0[(

Donald Williams, Deputy Associate DirectorRemediay J3r f1ch

d, .~-. -~fl;LCharlcs tfhry. Associate Director

Remedial Branch

c3~J-Jung Chiang, Assistant R~onal CodnsclRegional Counsel Superf ~d~

Mark Peyckl.:, CI ocrItc_'onal Counsel Superfund Branch

Samuel Coleman, P.E.Director, Superfund Division

\ 0/..:..3-,--' _~

\0/31Date'

003640

u.s. environmental protection agency announces the record

Documents